A mad dash to the end (or beginning) as FCC readies for an E-rate vote

Plus a few things we’re likely to know this Friday

Last night, about 40 minutes before the FCC filing system put up its “closed for business” sign, ALA filed a joint letter (pdf) with the Association for Rural & Small Libraries (ARSL), the Chief Officers of State Library Agencies (COSLA), the Public Library Association (PLA), and the Urban Libraries Council (ULC). The letter supports the proposed E-rate order (which is currently behind closed doors and under close review at the Commission in preparation for a vote on Friday). The letter is the result of extensive thought and negotiation among the library community–representing the smallest to the largest public libraries–and speaks to the shared vision that this E-rate order is a critical opportunity to dramatically improve library connectivity to and within the library building. Our message to the Commission and stakeholders at large:

We believe that the time to act is now so that changes made today in Washington, D.C., can take hold immediately in communities across the country… While our diverse organizations may differ on some of the details on the best path forward for program improvements, we are in agreement that to delay this important first step will shortchange our nation’s public libraries and the communities they serve.

Not only does the joint letter urge the Commission to move forward, it lays the groundwork for further strong library engagement in what is likely to be a continued reform process.

ALA filed its formula proposal, over which we have been stewing, well, for several months if not since last summer when the concept of a budget for the E-rate program first surfaced. After much input from ALA’s E-rate task force, network experts, state library staff, and library directors, among others, we arrived at a square foot model. Basing Wi-Fi and internal wiring service needs on the library’s square feet is a metric that can work for all sizes of libraries. It is not dependent on libraries reporting data that all libraries may not collect the same way (potentially leading to delays in funding down the road because of prolonged review by USAC). Libraries know and report their square footage as part of the data they are required to report to IMLS and therefore the numbers are publicly available (and easily checked by the Commission and/or USAC).

Gathering cost data as well as descriptions of how libraries design and implement their Wi-Fi networks resulted in a broad range of information that we distilled down to our proposal of $2.30 per square foot and a floor of 4000 square feet (or $9,200). Coming up with a refutable, robust, and reliable formula was a critical part of our advocacy at the Commission. Their current draft proposal appeared to be inadequate and, after an invitation from Commission staff to provide a better number, we were obligated to work a little harder and do a little more modeling (thank goodness for calculators and colleagues who can use them). We are gratified that PLA filed in support of the ALA proposal (also at the eleventh hour last night!). ALA is confident that the Commission hears our voice and is hopeful that the joint letter, our proposal and the independent support from PLA will help the Commission decide on a library formula that results in more libraries receiving more funding for Wi-Fi and internal wiring services.

But wait, what does all this mean…

Well that’s it exactly. Wait. After what has seemed like non-stop meetings, phone calls, letter drafting, and question answering, the public comment period is at an end. The Commission is set to vote on the draft order on Friday (3 more days!). At its open meeting, stakeholders will find out whether the draft order goes forward meaning that we’ll know

How the $2 billion down payment will be spent and we’ll know how the application process and administration of the program will be streamlined;

Which legacy services will be phased out and over what period of time, and

What issues related to building broadband capacity “to” the library and school the Commission puts on the table to take up in what we hope will be the very near term.

In the meantime, I plan to sit on my hands and patiently wait for Friday.

About Marijke Visser

As associate director of OITP, Marijke leads and coordinates all of ALA’s work on E-rate. In addition to E-rate, Marijke supports the Program on Networks focusing on broadband adoption issues for diverse populations. Marijke also serves as Program Director for OITP’s emerging portfolio on children, youth, and technology.